June 16, 2023

Special Emergency Connectivity Fund (ECF) News Flash

Contents:

• Announcements

Announcements

FCC Announces Final End Date and Deadlines for Emergency Connectivity Fund Program

The Federal Communications Commission (FCC) has issued formal notification that the Emergency Connectivity Program (ECF) will end on June 30, 2024. The FCC’s notice includes information about final deadlines to receive equipment, services, and reimbursements for ECF application windows 1, 2, and 3. These deadlines will depend on when schools received their original Funding Commitment Decision Letters (FCDLs) or Revised Funding Commitment Decision Letters (RFCDLs). FCDLs are initial commitment letters based upon original application values that are approved by the Universal Service Administrative Company (USAC). RFCDLs are issued upon approval of appeals and other post-commitment change requests (PCCRs) which are filed and processed after the initial FCDL is issued. All successful applicants will receive a FCDL. RFCDLs are rarer, and are triggered by actions undertaken by the school district applicant due to changes required in implementing ECF services or by appeals of adverse funding decisions. Applicants may search for PCCRs filed by their organization in the ECF application portal, or may call (800) 234-9781 to request assistance.

The following tables illustrate the program deadlines established by the FCC for each of the  ECF Filing Windows and corresponding FCDL and/or RFCDL issuance dates. Please pay careful attention to rapidly approaching deadlines for Windows 1 and 2 where funding was committed early and no post-commitment changes were made.

Deadlines for Recurring BroadbandServices:

Services include monthly broadband service plan charges.

Deadlines are established at the funding request level.

Deadlines for Equipment and Devices:

Services include laptops, tablets, and broadband equipment.

Deadlines are established at the funding request level.

It is important to note that some of these deadlines may need to be tracked manually at the individual funding request level until the Universal Service Administrative Company (USAC) is able to update its Open Data system with the correct and updated deadlines. In particular, the issuance date(s) of RFCDLs may create custom deadlines for the specific funding requests subject to the approved post-commitment change(s). If your application had multiple funding requests on an approved FCDL, but a post-commitment change request is approved for only a subset of the funding requests on the application, the deadlines for the funding requests with the approved post-commitment changes will be different than those that did not have any post-commitment changes.

The K12HSN will hold a webinar at noon on Wednesday, June 28, to review final invoicing and closeout requirements for the ECF program. To attend, please sign up at this link: https://icoe.zoom.us/webinar/register/WN_caveyEAiQLm9R3OOrfUg0A#/registration. Materials and a recording of the webinar will be posted on K12HSN’s ECF website.

ECF Window 3 Funding Status and De-Obligation of Funds

The Universal Service Administrative Company (USAC) continues to review ECF Window 3 applications and is issuing funding commitments on a regular basis. USAC is currently approving ECF applications at the 60% priority level. However, there is insufficient ECF program funding to issue funding decisions for all Window 3 applications. Any school districts who do not intend to use their approved ECF funding requests are encouraged to reduce or cancel their funding requests to de-obligate funds which may then be applied to pending ECF Window 3 applications. More information on returning funds may be found at USAC’s website.

Reminders about Filing Post-Commitment Change Requests

During the implementation of ECF, many schools may have encountered challenges in ordering and receiving services which may have resulted in a difference between what was approved on their funding request(s) and what was actually received. When this occurs, USAC will not process reimbursements until a post-commitment change request (PCCR) has been submitted and approved. Typical changes requiring a PCCR include the following:

➔ Who will invoice USAC (school vs. service provider)

➔ Service provider needs to change for some or all of funding request

➔ Change in services, service descriptions, part numbers, bandwidths

➔ Change service start and end dates

➔ Cancel or reduce funding request(s)

If your organization needs to submit a PCCR, we encourage you to do so in the ECF portal as soon as possible. More information and tips for filing PCCR requests may be found at K12HSN’s website, USAC’s video tutorial, and USAC’s ECF invoicing webinars and office hours.   

Reminders about Invoicing for ECF Reimbursements

The deadline to submit for reimbursement for the majority of Windows 1 and 2 ECF funding requests is August 29, 2023. Schools that intend to submit for reimbursement directly from USAC must certify their ECF FCC Form 472 (BEAR) in USAC’s online portal on or before the August 29, 2023 deadline. Schools are encouraged to start finalizing their reimbursements now as it is anticipated that USAC will receive an extremely high number of reimbursement requests on or around the August 29 deadline.

EXTREMELY IMPORTANT: The August 29 deadline is not eligible for extension through USAC. Even if you have a pending post-commitment request change, you should still file and certify your FCC Form 472 BEAR in USAC’s system on or before the August 29 deadline. In the narrative section of the form, provide an explanation of any pending post-commitment changes.

Each request for reimbursement must be accompanied by a vendor invoice supporting the amount requested. Vendor invoices must include the level of detail needed for USAC to validate the following information during its review of this supporting documentation.

• The date of the service for non-recurring charges, or the bill date for recurring charges, is consistent with what was entered on the ECF FCC Form 472.
• The date of the service or bill is acceptable based on the relevant funding period.
• The equipment or services provided are the same as what was approved on the ECF FCC Form 471 and are at the same or lower price point approved on the ECF FCC Form 471.
• The service provider who provided the equipment or services is the same as who was approved on the ECF FCC Form 471.
• The date that the service or equipment is delivered or shipped. 

More information and best practices for submission of BEAR reimbursement requests is available at USAC’s website. Schools are encouraged to work with their service providers to include delivery information on the invoice and reduce delays. Schools will receive outreach from the USAC Invoice Team via the Communications tab of the ECF Portal if any of this required information is missing. 

SAM.gov Requirement

Schools that request reimbursement directly from USAC with the ECF FCC Form 472 (BEAR) must have an Unique Entity Identifier (UEI) and have an active registration in SAM.gov. The SAM.gov registration requirement is NOT necessary if your organization exclusively uses the service provider reimbursement process (SPI) where the service provider invoices USAC directly and posts ECF funding as a credit on your bills.

BEAR filers should contact their internal business departments and/or departments that oversees federal funding to verify if their organizations have an active SAM.gov registration. If your organization is active in SAM.gov, verify that the Employer Identification Number (EIN) reported matches the EIN under your organization’s FCC Registration Number. Because many organizations obtained their FCC Registration Numbers many years ago, it may require some trouble-shooting to obtain a login for the FCC’s CORES system and to make any required updates. For help with CORES, please visit the FCC Registration Help Pages. You can also call the FCC Licensing Hotline, (877) 480-3201 Option 4, or visit the e-support page.

You may also look up your organization’s status, after creating a personal login at SAM.gov. Below are links to helpful videos if you are unfamiliar with SAM.gov and the registration process.

Search for Your Entity in SAM.gov:

https://www.youtube.com/watch?v=i0XE_rvP_RM

Obtain a Unique Entity ID:

https://www.youtube.com/watch?v=C87wSCYKTcE

Validate Your Entity:

https://www.youtube.com/watch?v=56NQ77JX5yo

Register Your Entity:

https://www.youtube.com/watch?v=IeZb5th5UAE

Renewing and Updating Your Entity:

https://www.youtube.com/watch?v=TNnCTYbGzH4

If you need help obtaining a UEI or have additional questions, please contact USAC’s Customer Service Center, Contributors/Service Providers option, at (888) 641-8722.

EXTREMELY IMPORTANT: The August 29 deadline is not eligible for extension through USAC. Even if you have a pending or expired SAM.gov registration, you should still file and certify your FCC Form 472 in USAC’s system on or before the August 29 deadline. In the narrative section of the form, provide an explanation of the actions you are undertaking to register your organization under SAM.gov.

ECF Compliance and Audit Preparation 

On March 1, 2023, the FCC issued a Public Notice reminding ECF participants of their ongoing compliance obligations. Specifically, the FCC reminds program participants of the necessity to retain asset and broadband service inventories for equipment and services purchased with ECF funds. Participants must also document “unmet needs;” in other words, retain documentation that ECF funds were used primarily to support students and school staff who would otherwise lack connected devices and/or broadband Internet access services sufficient to engage in remote learning. This documentation must be retained for 10 years and must be presented to auditors, upon request. The Public Notice may be viewed at this link: https://docs.fcc.gov/public/attachments/DA-23-166A1.pdf.

Required Asset Inventories

For devices, participants must retain an asset inventory tracking all the following items:

1) the device or equipment type (i.e., laptop, tablet, mobile hotspot, modem, router);

2) the device or equipment make/model;

3) the device or equipment serial number;

4) the full name of the person to whom the device or other piece of equipment was provided; and

5) the dates the device or other piece of equipment was distributed (or loaned out) and returned, or the date the school or library was notified that the device or other piece of equipment was missing, lost, or damaged.

Required Service Inventories

For broadband services, participants must retain inventories tracking all the following items:

1) type of service provided (i.e., DSL, cable, fiber, fixed wireless, satellite, mobile wireless);

2) broadband plan details, including: upload and download speeds and monthly data cap;

3) the name(s) of the person(s) to whom the service was provided;

4) the service address (for fixed broadband service only); and

5) the installation date of service (for fixed broadband service only); and

6) the last date of service, as applicable, (for fixed broadband service only).

Additional ECF Compliance Information Issued by USAC

In a recent newsletter, USAC issued additional guidance to ECF program participants regarding compliance with program rules. USAC emphasized the following:

• Reimbursement may only be requested if there was an actual unmet need
• Reimbursement should not be requested for monthly recurring services associated with any devices or equipment that are not being used
• ECF funds are not intended to support 1:1 initiatives but may only be used to support students and staff who have a documented unmet need
• ECF funds are not intended to support devices and services used exclusively on a school campus, they are primarily intended to support remote learning away from school

We encourage schools who have claimed ECF funds to ensure that they are in full compliance with ECF program rules and requirements. More information may be found at the FCC’s website, the FCC’s Frequently Asked Questions website, and K12HSN’s ECF resources.

Single Audit

In addition to the possibility of an FCC program audit, public school districts must comply with Federal Single Audit requirements for any year their organization receives over $750,000 in Federal Awards. More information about single audit requirements for may be located at the SAM.gov assistance listing website and the White House OMB website.